I went to law school in the early 1990s so I’m supposed to be a John Grisham fan. The lure of doe-eyed law school graduates getting hired by big law firms paying big salaries was shadowed by the sinister practices in The Firm. I did read Grisham’s first few books and stopped. I enjoyed the … Read more »
Compliance Bricks and Mortar for Pi Day
Exploratorium physicist Larry Shaw began celebrating March 14 as pi day for the mathematical constant π, the ratio of a circle’s circumference to its diameter. Behind the Myth of Insider Trading by SEC Employees by Bruce Carton in Compliance Week The authors also point to six specific cases in which “SEC employees appear to front-run … Read more »
Get Ready for the SEC to Knock on Your Door
With the SEC’s presence exam initiative for new registrants and the Never-before-examined initiative for existing registrants, the odds have never been greater that the SEC will knock on your door and start an examination. I’ve also heard from a friend that the SEC is coming in for a full blown examination of her firm. (I … Read more »
Do U.S. Regulators Listen to the Public?
Regulators get piles of comment letters on proposed rules. But do the comments have an affect? Three math and finance professors tried analyzed the text of comments and regulations to find and answer. Andrei A. Kirilenko, Shawn Mankad, and George Michailidis created a regulatory analytical tool called RegRank. The three researchers pointed RegRank at the … Read more »
New Ruling on a Social Media Policy – Come on Down!
The National Labor Relations Board continues to wreck havoc on companies’ social media policies. That latest to get steamrolled in Boch Honda. I grew up with Ernie Boch’s commercial proclaiming that his costs are less so his prices are less, so “come on down“. Employers cannot prevent employees from discussing their conditions of employment with … Read more »
Do Law Firms Need Compliance Programs?
Do as I say; Not as I do. The bankruptcy of Dewey & LeBoeuf sent shivers throughout big law firms. The firm could trace its history back 100 years and employed over 1000 lawyers when it exploded. Last week, key leaders of the firm were charged with securities law violations and criminal theft charges related … Read more »
Weekend Reading: Wheelmen
There are compliance lessons to be learned in Wheelmen: Lance Armstrong, the Tour de France, and the Greatest Sports Conspiracy Ever by Reed Albergotti and Vanessa O’Connell. Lance Armstrong was one of the best cyclists in last 20 years. But his wins were built on a foundation of illegal doping and performance enhancing drugs. It’s … Read more »
Compliance Bricks and Mortar for March 7
These are some of the compliance-related stories that recently caught my attention. Machiavelli for Chief Compliance Officers by Tom Fox in the FCPA Compliance and Ethics Blog Lesson No. 1 – Heed Selected Advice from Selected Advisors While in medieval Florence, the Prince ruled as the supreme monarch, he still needed advisors. Today, we are … Read more »
Compliance Lessons From My Dog
My dog has taught me a few lessons about compliance. (That’s me and Ghost taking a well-deserved nap.) Start early. We started dog training early to focus on developing good habits at an early stage. (We did lose a few shoes while he was a puppy.) It’s never too late to unlearn bad habits, but … Read more »
Create an Introduction for the SEC
The chances are greater than ever that the Securities and Exchange Commission will show up in your lobby. Be prepared and have an introductory presentation for them. The SEC’s Office of Compliance Inspections and Examinations is continuing on its presence exam initiative. Those exams are shorter which means the examiners can get to more fund … Read more »